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Governance

Ethical Management

Ethical Management System

Ethical Management Implementation System

SK D&D upholds not only its economic and legal responsibilities, but also its ethical and philanthropic obligations, by establishing a Code of Ethics that serves as a foundation for decision-making and conduct across all business activities. This Code is regularly reviewed by the Internal Control Part and revised through discussions with relevant business support departments and final approval from the CEO. All employees of the domestic headquarters and subsidiaries are required to participate in the "Code of Ethics Compliance Pledge" in accordance with Article 22, Chapter 4 of the Code. SK D&D conducts its business honestly, fairly, and transparently with all key stakeholders, including customers, employees, and business partners. To manage ethical risks effectively, SK D&D operates a comprehensive “Prevent-Detect-Respond” framework. This process aims to prevent ethical risks in advance, monitor continuously, and respond promptly to any issues that may arise.

Key Contents of the Code of Ethics

Ethical Management Governance Structure

Ethics Management Organization

SK D&D promotes ethical awareness and integrity among its members through the Internal Control Part, the department responsible for driving ethical management initiatives. Each year, the company conducts ethics training, ethical management workshops, and collects signed pledges of ethical commitment from employees. These efforts are aimed at fostering and strengthening a culture of ethics across the organization. As a department under the Audit Committee, the Internal Control Part also oversees external audits, the internal accounting management system, internal audits, and related risk assessments. An annual audit plan—covering both internal and ethics/anti-corruption audits—is developed and reported to the Audit Committee under the Board of Directors. The Audit Committee reviews the overall plans and outcomes of ethical management activities, monitors the implementation of improvement measures, and contributes to the establishment and advancement of a transparent and accountable ethical management culture.

Ethical Management Organization

Internalization of Ethics Management

Ethics Management Training

Ethics Management Training Program

SK D&D promotes a sound ethical culture across the company by operating ethics and anti-corruption training programs for all employees, including contract workers. In addition to mandatory annual legal trainings—such as disability awareness, workplace harassment prevention, and sexual harassment prevention—SK D&D offers a wide range of training curricula. These include guidance on using the SK Ethics Management Reporting System, case studies, and discussions on workplace misconduct. All employees participate in ethics training with a 100% completion rate each year, reinforcing the company’s ethical management awareness.

SK D&D also holds an annual Ethics Management Workshop to strengthen ethical awareness among all employees. These workshops facilitate cross-hierarchical and cross-functional discussions on proper decision-making in ethically challenging situations. In 2024, the workshop was conducted for 178 employees and executives by level and department, with approximately 96% participation. Additionally, to cultivate shared values and promote ethical practices, the company distributes a quarterly Ethics Management Letter and implements awareness campaigns such as prohibiting the exchange of gifts with business partners during holidays.

2024 Ethics Management Training and Achievements
CategoryFrequencyActivity DescriptionParticipation Rate
Ethics Management Letter4 times/yearQuarterly updates on ethics management plans and performance100%
Ethics Practice PledgeOnce/yearSigning the pledge to adhere to the ethics code and ethical conduct guidelines100%
Online Ethics Management TrainingOnce/yearGuidance on workplace harassment cases and how to use the reporting channel (“Communication Hotline”)100%
Mandatory Ethics Education5 times/yearTraining on disability awareness, prevention of workplace sexual harassment and bullying, data privacy100%
Ethics Practice WorkshopOnce/yearEnhancing ethical decision-making skills by rank and department; sharing feedback on internal policies and issues96%
Holiday Ethics Compliance NoticeTwice/yearEncouraging ethics compliance and gift reporting during holidays for employees and partners (including updates on anti-graft laws)100%

Ethics Risk Monitoring and Audit

Ethics Risk Monitoring

Ethics Risk Detection System

SK D&D operates a self-regulation system across its headquarters and subsidiaries to prevent corruption and unethical behavior in business activities. Departments responsible for key business areas autonomously monitor the current status of ethics risks.

Ethics and Anti-Corruption Audit

SK D&D conducts regular annual ethics and anti-corruption risk audits at all operating sites, including headquarters and subsidiaries. In 2024, audits focused on the prevention and management systems for ethics and corruption risks within subsidiaries, including reviews of regulations, roles and responsibilities, and processes. When ethics or anti-corruption risks are identified through internal audits, the findings are reported to the Audit Committee. The Internal Control Department then implements corrective actions or works collaboratively with relevant departments to address and mitigate these risks.

Ethics Management Practice Survey

To assess and improve the level of ethics management practices, SK D&D conducts an annual ‘Ethics Management Practice Survey’ for all employees and business partners. Since its introduction in 2015, the survey evaluates ethics practice levels, organizational ethics culture and systems, and types of unethical conduct. Based on the survey results, key areas for improvement are identified and used to enhance the company-wide ethics management framework and related activities. In addition, a ‘Supplier Ethics Management Survey’ is regularly conducted with business partners. In 2024, SK D&D reviewed ethics violations related to purchasing contracts among employees of 69 major suppliers and found no significant issues.

Ethics Management Reporting Channels

SK D&D operates two primary ethics reporting channels: the SK Group-wide ethics reporting system, “SK Ethics Management,” which is accessible to all stakeholders, and the “Communication Hotline,” dedicated to investigating unethical behavior such as lack of respect for the dignity of internal employees. These channels allow anonymous reporting of unethical conduct by employees, unfair trade practices, and other issues, while strictly protecting the identity and confidentiality of the whistleblower. SK D&D ensures that whistleblowers do not suffer any disadvantage or discrimination due to their legitimate reports by maintaining a comprehensive whistleblower protection system. Notably, the “Communication Hotline” is managed by an independent third-party organization, minimizing contact between employees to ensure objective and transparent investigations.

SK D&D Whistleblowing Channel

  • *SK Ethical Management: SK D&D Internal Control Part / skdnd.ethics@sk.com
  • **Sotong Hotline: SK D&D People & Culture Part

Types of Whistleblowing

Whistleblower protection program

Whistleblowing procedure

Status of Ethical Management Reports and Resolutions

In 2024, SK D&D received a total of nine reports related to ethical management. These included cases involving unfair practices and abuse of power toward partner companies, lack of mutual respect among employees, improper handling of work duties, legal non-compliance, violations of internal regulations, and other customer-related complaints. Each report was thoroughly investigated through internal procedures, and appropriate actions were taken to address the issues. All reported cases were resolved and formally closed following the implementation of the necessary corrective measures.

Status of Ethical Management Reports
CategoryUnit202220232024
ReportingType of ReportUnfair practices and abuse toward partnersCases112
Lack of respect among employeesCases002
Conflict of interest in job dutiesCases000
Improper job handlingCases042
Undermining of social valueCases000
Legal compliance violationsCases001
Violation of internal ethics regulationsCases000
Others (e.g, civil complaints, non-managed)Cases741
Number of Violations by reporting channel*Number of ViolationsCases--8**
Number of cases addressedCases--8
Subject of Report*EmployeeCases--5
Partner companyCases--3
CustomerCases--0
OtherCases--1
Category of Report*Other reports receivedCases--2
Discrimination and Harassment casesCases--2***
Anti-corruption casesCases--5
Disciplinary actionsDismissalCases000
SuspensionCases001
Salary ReductionCases000
Reprimand/WarningCases151
Under InvestigationCases000
TransferredCases001
OthersCases746
Processing Rate%100100100
Anti-corruption case handling statusResult of Anti-corruption CasesNumber of casesCases000
  • *Items newly disclosed and managed from 2024; no data available for 2022–2023.
  • **Of the total nine cases, one was closed and excluded due to "lack of investigation authority."
  • ***The two cases reported as discrimination/harassment pertain to the same matter and have been resolved with disciplinary action by the HR Committee.